July 31, 2015

In response to the letter from the FAA , Brenda Robeson, Program Analyst, Airmen and Airspace Rules Division : Cannot Process Request Docket number FAA

- 2015

- 0921

Question 1: The reason why granting the request would be in the public interest , that is, how it would benefit the public as a whole.

Answer:
Granting this exemption to Flying Tigers Aviation will benefit the public directly in several ways. Flying Tigers Aviation provides contract workforce training for Louisiana Delta College in th e areas of aviation education , agricultural aerial application, and public service /emergency response

. All of the areas are focused on support to the rural NE Louisiana and Mississippi Delta region. The demographics and geographies of the Delta are captur ed in the areas requested under this exemption.

Education:
By granting this exemption, Flying Tigers Aviation will be able to train competent operators through the Louisiana Delta College work force training program for many drone applications. These opera tors will use UAS in ways that will increase safety to ground crews in dangerous or disaster situations, help to increase crop yields, and reduce pollution from fertilizers and pesticides as well as provide wildlife management support. The goal of UAs tra ining is to realize more precise agricultural use of chemicals to improve crop yields while reducing any negative impact on the environment. Pilot and sensor operators trained through this program will be able to locate problem areas and target them dire ctly, rather than blanket spraying entire fields with chemicals. These operators will then have the advantage of being qualified to enter a new sector in the labor force of the US economy.
Agriculture:
UAS can be used in ways that allow a targeted approac h to the application of treatments for many problems that impact the growth of crops. The use of UAS is being validated daily for its ability to increase the efficiency of farmers through crop surveillance and precise chemical application . This directly tr anslates into higher production rates of food for the US and other nations. This “precision agriculture” approach also translates into fewer pesticides, herbicides, and fertilizers being released into the environment. This can have a trickle

- down effect of reducing pollution in rivers and lakes, which has a positive impact on the aquatic life in those bodies of water.

Public Service /Emergency Response :
UAS can be used in response to disasters such as hurricanes, floods, earthquakes and others. They can

cr eate a safer approach to information gathering for the crews deployed to these disaster areas, and provide them with a means to make better decisions about how they will save lives, while not riskingtheir own. One example would be an earthquake situation where there is a factory with dangerous

chemicals that may be on the verge of collapse. A UAS can be deployed to survey the damage and to scout a safe route into the structure, allowing rescue crews to reach victims in a quick and much safer manner than if they did not have an aerial view of the scene. In the Delta region there are routine natural disaster events such as flooding, tornadoes and hurricanes where the UAS can provide immediate disaster response support in ways that will save lives and enhan ce ground unit effectiveness.
It is the intent of Flying Tigers Aviation to approach these areas and others in a way that will improve the quality of life and the safety of everyone involved and all that could be affected by the results of the operation of UAS.
Question 2: The reasons why the exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek an exemption.
Flying Tigers Aviation is a professional co mpany which holds safety to a very high standard. The DAx8 will be operated in the same manner as a full size aircraft. Below are some examples of the safety considerations that affect the operation of the DAx8

.

- The safety of full size air traffic is a to p concern. Communication with full size aircraft for de

- confliction will protect passengers and pilots of full size aircraft by keeping the UAS out of airspace occupied by full size aircraft , and to notify full size aircraft of the operations so that they can avoid the UAS operation

area.

- Safety of bystanders and operators is also a top priority. Airspace will be cleared, and overflight of people will be avoided. Bystanders will be notified of the use of the UAS and will be instructed by the flight crew so that they are aware of any precautions necessary to ensure safe cooperation between the UAS and people on the ground.

- Pilots will be trained by Drone America or Flying Tigers Aviation in the specific operations of the DAx8. They will be validated

- The u se of checklists, good planning practices, and attention to detail will ensure safe operations.

- The aircraft will not be operated outside of the manufacturers specified limitations.

- A preflight inspection is performed prior to every flight, which is al so part of a continual maintenance

- The aircraft will be operated by licensed pilots who have already been trained in manned aerial application operations over the same exemption areas.

Mr. Lawrence L. Rolfs Flying Tigers Aviation , LLC P.O. Box 238 Oak Ridge, LA 71264